A question from a recurring customer on 09.04.20:
We received the below note from our packaging supplier in regard to testing. We supply a hazardous material for transportation and ship using these boxes. Has there been any changes that you know off that would help us decide if the testing is necessary?
MESSAGE FROM PACKAGING SUPPLIER:
Good morning and hope all is well. The UN Certification on your 6 X 32 OZ UN SHIPPER is set to expire in November. If you plan to renew this UN certification, please ship the below test components to <<city, state>> to my ATTN at your earliest convenience. When received, the test regimen will be scheduled. Current lead time for testing is 8-10 weeks. Also, please issue a purchase order for this re-test to orders@<<company>>.com. Cost per UN Test is $1895.00.
- 6 X 32 OZ UN SHIPPER
- 13 Complete Cartons: Item # 30060/30060P
- 78 32-OZ Brown HDPE BR Bottles: Item # 20205
- 78 28/400 White Child Resistant Screw Caps: Item # 2C205
- Closure Tape (Customer Provided): ULINE S-3267 2” Poly Tape
If you have any questions, please let me know.
By the way we have a large inventory of boxes and bottles that were certified when we bought them.
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I thought I could help but I required more information:
I can assist you. I require more information. Please see below.
- An image of the packaging would be helpful.
- What is the DOT specification / UN standard? It should be displayed on the side of the packaging.
- What is the hazardous material to be packed and shipped in this packaging?
Thank you and please advise.
It took him a few days to reply with the information I requested (09.08.20):
Here is the info you asked for, thanks in advance.
He also provided a safety data sheet (SDS) for the product that confirmed it was a HazMat.
My reply that same day:
Please see below.
- The packaging in the image is marked to indicate it is designed, manufactured, and tested to indicate it meets a UN standard.
- The packaging met this UN standard as of its manufacture in 2018.
- It is authorized for use within the the U.S. and is acceptable for transportation of hazardous materials wherever the UN standard is accepted (most of the world).
- Any recertification of the packaging design is done by the packaging manufacturer or their agent.
- There is no need to renew a UN certification on packagings that have already been manufactured.
In short:
- The packagings you have in inventory marked as the above are fine for use.
- There is no life-span on the use of this type of packaging. i.e., you could sit on these for 10 years and they would still be acceptable for use unless the UN standard for packagings changes in that time. Note: some plastic packagings have a five year lifespan under the international regulations and also within the U.S. if they are reused.
- I don’t know what the packaging supplier is referring to.
I hope this helps. Please contact me with any other questions.
He was grateful:
Thanks Daniel as usual you are a big help.
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Conclusion:
I don’t know the entire story – I never spoke with the packaging supplier – but I am confused by what they seemed to be requesting. I wish to think that the supplier of a HazMat packaging would know the regulations well enough not to make a costly mistake like this, but I think this one did. Make certain you are aware of your responsibilities under the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA).